International Tax

Canada vs Thompson: Exploring the Limits of Solicitor-Client Privilege in Tax Enforcement

In Canada (National Revenue) v. Thompson, the Supreme Court of Canada evaluated the boundary between solicitor-client privilege and the statutory obligations imposed on lawyers under the Income Tax Act (ITA).

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Orde van Vlaamse Balies vs Belgium: Legal Privilege and Cross-Border Tax Reporting Obligations

In Case C-694/20, the European Court of Justice (ECJ) examined the legality of certain reporting obligations imposed on lawyers under Council Directive 2011/16/EU (as amended by Directive 2018/822).

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F SCS vs LUXEMBOURG: Safeguarding Lawyer-Client Confidentiality in Cross-Border Tax Inquiries

This case focuses on whether the Netherlands’ national tax law, which restricts the deduction of interest paid on intra-group loans in certain scenarios, is compatible with the freedom of establishment under Article 49 TFEU.

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Introduction to International Taxation: Key Concepts & Guidelines

International taxation governs the tax framework applicable to cross-border activities of individuals and corporations. It addresses the tax treatment of income earned by residents in one country from foreign sources and non-residents from domestic sources.

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Emerging Transfer Pricing Trends in Africa: Insights from Dr. Daniel Erasmus at the 13th Annual Africa TP Summit

In this insightful address at the 13th Annual Africa Transfer Pricing Summit, Dr. Daniel N Erasmus explores the most pressing trends in transfer pricing across Africa and developing regions.

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Understanding the Comparable Profit Method (CPM) in Transfer Pricing

The Comparable Profit Method (CPM) is a widely used approach in transfer pricing, employed to ensure that transactions between related entities (often within multinational enterprises) align with the arm’s length principle.

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Hyatt International vs. India (ADIT)

Hyatt vs India (ADIT) tackles several pivotal issues regarding the attribution of income to a Permanent Establishment (PE) in India, even in cases where the global entity has incurred financial losses.

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General Motors v. ACIT, Circle International Taxation 1(3)(1), New Delhi

The Income Tax Appellate Tribunal (ITAT), Delhi Bench, ruled in favour of General Motors USA in a case revolving around the Double Taxation Avoidance Agreement (DTAA) between India and the USA. The core issue concerned whether the assessee, an LLC, could be considered a “resident” for tax purposes under Article 4 of the India-USA DTAA

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General Court Judgment in Amazon and Luxembourg v European Commission

The General Court of the European Union ruled in favour of Luxembourg and Amazon, annulling the European Commission’s decision that Luxembourg granted illegal state aid to Amazon through tax rulings.

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Tax Planning in International Taxation: Navigating Compliance and Avoidance

International Tax Planning is a crucial aspect for multinational corporations seeking to optimize their global tax obligations. With the increasing complexity of international tax laws and regulations, tax planning offers a strategic approach to ensure compliance while minimizing tax liabilities.

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